ML20050A711
| ML20050A711 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 02/19/1982 |
| From: | Roberts T NRC COMMISSION (OCM) |
| To: | Harold Denton, Dircks W Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20050A708 | List: |
| References | |
| NUDOCS 8204020124 | |
| Download: ML20050A711 (1) | |
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UNITED STATES
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f February 19, 1982 OFFICE OF THE COMM10SIONER MEMORAllDUM FOR: William J. Dircks Executive Director for Operations Harold R. Denton, Director Nuclear Reactor Regulation FR0ft:
Commissioner Roberts q
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SUBJECT:
PUBLIC SERVICES COMPANY OF OKLAHOMA LETTER j
OF FEBRUARY 16, 1982, TO HAROLD R. DENTON e
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I would appreciate having jour written views on this letter.
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P.O. BOX 201/ TULSA, OKLAHOMA 74102 / (918) 599-2000 '82 FE818 P3:52 TO "'Y c,rri,, c t,r, s,.
February-16, 1982 nnw r C.G y,(.-
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Mr. Harold R.
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((/' # ]b h4 Director, Office ~of Huclear Reactor Regulation TH
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Nuclear Regulatory Commission t
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Dear Mr. Denton:
Re.
In the matter of Black Fox Station Units 1 and 2; Docket Nos. STN50-556 and STN50-557 Public Service Company of Oklahoma, Associated Electric Cooperative, Inc., and Western Farmers Electric Cooperative, co-applicants for Construction Permits in the subject docket, are announcing today the cancellation of the Black Fox Station.
This letter follows a verbal notification to your office today by our Washington, counsel.
I feel it is incumbent upon this company, as project manager, to O explain at some length the reason for our actions.
In essence, the D action
+- a k o n is necessitated by a continuina climate of oolitical a,n_d__mgn i n +- n *v uncertainty at the federal level _.
The project has regrettably become economically unattractive due to the sharp in-crease in project costs brought about by the almost three-year licensing moratorium imposed by the U.
S.
Nuclear Regulatory Com-mission.
The Elack vnv owners have always believed themselves to be c' aught in a unique time warp, i.e.,
that of having instituted work under a__Limitna wn-F Anthnri~ a H nn and havina the safetv hnarinc rne nrel complete orior to the event n ne mhroa Mile Island.
No otlier pending construction permit applicant was in that situation.
PSO, as project manager, has been more than responsive to the events at Three Mile Island.
0"* net 4 ~ W.m b e n nnM M p,*n y n# naw recui rementn and have found us pro-acting as a demonstration of our.
commitment to do that which was required to place the Black Fox licensing back on track.
You know we led the industry in these responses, and. are instrumental in forming and leading a Near-Term Construction Permit working group to interact with your staff in establishing the licensing basis for the pending applications.
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.y Mr. Harold R.
Denton, Director February 16, 1982 QT\\
Office of Nuclear Reactor Regulation Page 2 e,ff
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During this effort, you met personally with executives and representa-tives of this company many times to assure us your good will and ultimate licensability of our project.
$ctwithstanding our efforts, we cannot help but feel we were ignored through 1979, tcyed with during 1980, and disappointed in 1981.
'Despite your assurances to the contrary, we have found no real com-mitment to progress or licensing stability following the events-at Three Mile Island or the several investigations.
To be absolutely frank Pnh14c Ra"vi ca company, as proiect manacer_,
and all three companies.as. owners, have no confidence in the orocess; or
that it will allow completion of the units as planned on any reason-ably foreseeable schedule or operation of the units on a reliable b~ asis throughout their expected lifetime.
I must here repeat the thrust of the argument set forth in our response to the proposed licensing rules published on October 2, 1980, and March 23, 1981.
That is, if there were a safety problem associated with the changes therein mandated for plants under con-struction, your Agency would have immediately revoked their Construc-and some of those units are identical to Black Fox in
[TD tion Permits,
(';l vintage and design.
This having not been done, the Agency, by halting progress at Black Fox, has exhibited a bias born of political percep-tion, not of technical necessitude.
rIndeed, the ultimate irony is that only today do the post-TMI rules for the pending Construction Permit applications become effective, with the " lessons learned" being substantially the same as were identified by your office in the fall of 1979.
l The ef fects of inflation on project costs during this period have been staggering; moreover, thn nromise of future backfieeing recnirn-nnly mnnn
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- bn cnne nr *hn prnject will cnn*inno en men;n c,,
eggalaen ne nnmn unknnwn and uncontrollabin vn*n.
The extensive delays in setting the requirements for granting nuclear Construction Permits have narrowed the nuclear economic advantage over coal-fired alternatives to the vanishing point.
When you combine this with the financing difficulties associated with the absolute magnitude of the investment as now estimated, and the political, regulatory, and economic uncertainty that attend nuclear power; termination of the project becomes a necessity born of prudent management.
The corporate risks of doing otherwise are simply untenable to all of the companies involved in this venture.
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';'l'k Mr. Harold R.
Denton, Director February 16, 1982 Office of Nuclear Reactor Regulation Page 3 i
We intend to preserve the site for construction of future power generation projects, hence most of the activity pursued on the site itself under the Limited Work Authorization will be convertible to alternatively fired generating facilities.
The timing for these facilities is uncertain, but will undoubtedly have to commence within the foreseeable future to replace the capacity which was being relied upon from the Black Fox facility.
I have, at this date, directed counsel for the co-applicants to seek withdrawal of the application from the Atomic Safety and Licensing Board, as provided in 10CFR, Section 2.107.
Your staff should continue to direct any questions to Dr. John C.
Zink, our Manager of Licensing.
Black Fox Station has always been a good management decision; the need for nuclear-fueled ceneration is indisnutablei it is regret-table that outside, uncontrollable circumstances did not allow its pursuit in a reasoned manner by individuals at companies committed to achieving excellence in every aspect of the project.
Very truly yours, s.
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MEF:VLC:lh cc:
BFS Service List Office of the Commissioners, USNRC Nunzio J.
Palladino, Chairman Victor Gilinsky Peter A.
Bradford John F.
Ahearne Thomas M.
Roberts i
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